Anti-Bribery & Corruption Policy
1. Purpose
This Anti-Bribery & Corruption (ABC) Policy is to further enforce the G Gen Labs
Code of Conduct & Business Ethics to ensure that employees understand their responsibilities in compliance with G Gen Lab’s zero tolerance for bribery and corruption within the organisation.
2. Policy Statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as
an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to
counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws in Malaysia
under Malaysian Anti-Corruption Commission Act 2009, in respect of our conduct
both at home and abroad.
Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and a fine. If we are found to have taken part in corruption, we could face an
unlimited fine, be excluded from tendering for public contracts and face damage to
our reputation. We therefore take our legal responsibilities very seriously.
3. Scope of Policy
3.1 Who is covered by the policy?
In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all individuals working at all levels and grades (whether permanent, fixed-term or temporary), including:
⁃ Directors
⁃ Senior officers
⁃ Executives
⁃ Employees
⁃ Consultants
⁃ Contractors
⁃ Trainees
⁃ Agency staff
⁃ Interns
⁃ Agents
⁃ Any other person associated with us, or any of our subsidiaries or their employees, wherever located
3.2 Bribes
Employees must not engage in any form of bribery, either directly or through any
third party (such as an agent or distributor)
3.3 Gifts and Hospitality
3.3.1 The following are policies for gifts and hospitality:
⁃ The intention behind giving or receiving any gifts, hospitality or entertainment
must always be considered first. It should never be for an improper motive to
obtain or retain a business, or to obtain some form of benefit or advantage,
whether it is for the business or for the individual employee
⁃ If an employee is unsure of how to consider the intention behind any gifts,
hospitality or entertainment offered, the employee must always disclose and
refer the matter to the immediate supervisor or head of department to obtain
advice and also approval before proceeding
⁃ All employees of G Gen Labs are not allowed to give or receive any gratification, gifts, hospitality or entertainment where it is for an improper purpose and
can be deemed as a gratification, regardless of whether it is to benefit the employee individually or to benefit the business of any of G Gen Labs
⁃ An employee must obtain prior clearance and approval from the immediate
supervisor and/or head of department before giving or receiving any gifts, hospitality or entertainment to or from any person which is not of any improper
motive.
⁃ Where any gifts, hospitality or entertainment is not improper and received before prior approval can be obtained, an employee must always disclose such
gifts to the immediate supervisor and/or head of department, regardless of its
value.
3.3.2 Any gifts, hospitality or entertainment provided by G Gen Labs must always
be of moderate and reasonable value and should never be given:
⁃ With an intention to exert improper influence or create a perception of expectation for certain outcomes beneficial to the business of G Gen Labs.
⁃ Where it may cause a conflict of interest.
3.4 Facilitation Payments
Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and
not to obtain or retain business or any improper business advantage. Our strict policy is that employees should ensure these facilitation payments are not be paid.
3.5 Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
3.6 Donation, Sponsorship & Charitable Contributions
⁃ Any donations, sponsorships and charitable contributions by G Gen Labs
must be done with the approval of the executive director(s) and it must be
done in a transparent manner for social and moral responsibility.
⁃ It should never be paid in exchange for any business implications to G Gen
Labs, whether it is to obtain a business, or to obtain some form of advantage
of the business of G Gen Labs.
⁃ Employees are encouraged to make donations and charitable contributions in
their personal capacity, but it should never be in exchange for any improper
purposes that affects the business of G Gen Labs.
4. Employees Responsibility
Employees must adhere to the following:
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or the Company Secretary or the confidential helpline as soon as possible if you believe or suspect that a conflict with or breach of
this policy has occurred, or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy
5. Record Keeping
In regards to record keeping:
⁃ We will keep financial records and have appropriate internal controls in place
which will evidence the business reason for making payments to third parties.
⁃ Employees must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
⁃ Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
⁃ All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.
6. Violations of Anti-Bribery & Corruption Policy
6.1 Any violation of the ABC Policy by employees of G Gen Labs will attract serious
repercussions and disciplinary action after due inquiry. Where there is strong evidence of bribery and corruption committed by any employee of G Gen Labs, the employee can be summarily dismissed and will not be allowed to be employed in any other companies of the G Gen Labs.
6.2 Employees who are found to have assisted or facilitated the violation of the ABC Policy, whether actively or by way of negligence or omission, will also be deemed to have violated the ABC Policy and committed a misconduct that is liable for dismissal from their employment with G Gen Labs.
7. Reporting Violations or Policy & Whistleblower Rights
7.1 Where there are reasonable grounds and genuine reasons to suspect that there
is a violation of the ABC policy, employees of G Gen Labs and Other Applicable
Persons are required to report the particulars of such suspicions to G Gen Labs
dedicated channel for reporting. Any such reports will be read and addressed by a
dedicated compliance team in G Gen Labs.
7.2 Any concerns, questions or reports should be addressed to firstly, their immediate supervisor or Head of Department, or where that is not possible, to other functions such as the Human Resource Department, Legal, and Internal Audit.
7.3 Any reports made for violation of the ABC Policy will be treated very seriously
and accordingly, employees are responsible to ensure that they exercise sound
judgment, have evidence and are available to provide evidence to a genuine threat
and violation to the ABC policy
7.4 G Gen Labs ensures that there will be no retaliation or repercussions on the
employee for making genuine reports on violation of the ABC Policy. Any genuine
reports made will be kept strictly confidential and only informed to persons on a
need-to-know basis to safeguard the interests of G Gen Labs and also to ensure
that any processes undertaken will not be compromised.
8. Compliance and Review of Policy
The Company Secretary will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, effectiveness, as
well as to ensure continued compliance with the prevailing law. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Company Secretary.
This policy does not form part of any employee’s contract of employment and it may be amended at any time